Set yourself up for a great start
In the spirit and goal of becoming, or remaining, a lean and mean — or efficient and successful — business this year, turn your focus to processes involving billing and coding for the services we provide.
The four areas listed below serve to set the stage as a preamble to later discussions. Note: When I recommend that we focus on something, that is my way of saying “please check on it now — because if not, it may be looked at later by someone else with repercussions if their view of it is negative.”
1 REGISTRATION
Be certain your provider entity, and each individual provider within that entity, is properly registered with CMS. What’s more, list each provider in your practice properly on each claim.
2 ATTESTATION
Update your attestation on Council for Affordable Quality Healthcare, including the email to which they send notifications of future required attestations. (Find more information at bit.ly/CAQHproview .)
3 LOCAL COVERAGE DETERMINATION
Look up and save each Local Coverage Determination (LCD) relevant to your practice, and be specific to your state, if applicable. (For more on LCD, see “Homework,” at below.)
4 KEEP ALERT
Watch for a very important rule change soon to take place regarding who is required to enter chief complaint. Additionally, review history of present illness documentation within your EHR system.
START AT THE BEGINNING
Compliance, efficiency and success in billing and coding processes tend to come up throughout the year. In order to avoid this in 2019, start at the very beginning with the overall process to set yourself up for success. OM
HOMEWORK
In preparation for upcoming coding columns, I would suggest everyone look at the Local Coverage Determination (LCD) for your state, and print each one that applies to procedures you perform in your practice. (The LCD is simply Medicare’s payment vs. the non-payment rule book. Thus, any billing and coding compliance protocol you build in your practice should follow these guidelines in order to abide by your provider contract with Medicare beneficiary coverage.) A good plan for the beginning of every year is to review the LCD for each procedure offered in your practice. To find the LCD by state, visit https://go.cms.gov/2F6zthw .
Each carrier has payment policies and rules they follow for processing claims involving many of the common procedures we provide in our practices. In the LCD, you will find these coverage guidelines, including coverage indications, limitations and/or definitions of medical necessity. In some states, there may not be an LCD for a specific procedure. If that is the case, follow the national coverage determination, or NCD, for that procedure.
I recommend keeping the LCD for the current year until you are past the time you may be audited, which can range from a four to 10-year look-back period.
For example, if you are audited regarding records from date of service 2015, it is important to have kept the LCD for that year to be certain you are referencing rules that were in place at that time and not the rules that are in place today, as they could be different.
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